Ann M. Wilson - Page 7

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          satisfies the requirement to substantiate items.  Sec.                      
          7491(a)(2)(A).  Petitioner has not offered any evidence that she            
          satisfies any of the criteria of section 7491(a)(2)(A).  The                
          burden of proof has not shifted to respondent; therefore, it                
          remains on petitioner.                                                      
          1.   Head of Household                                                      
               Section 1(b) imposes a special tax rate on an individual               
          filing as a head of household.  As relevant herein, section 2(b)            
          defines a “head of household” as an unmarried individual who                
          maintains as his or her home a household that for more than one-            
          half of the taxable year constitutes the principal place of abode           
          of an unmarried child of the individual.  Sec. 2(b)(1)(A)(i).               
               Petitioner’s eligibility for head-of-household filing status           
          primarily depends on whether she maintained a home that for more            
          than one-half of the taxable year was the principal place of                
          abode of her daughter.  A key factor in resolving this issue is             
          whether RW’s absence from petitioner’s home, while attending high           
          school in Indiana, can be considered a temporary absence.                   
               In January 2000, petitioner moved from Indiana to San                  
          Diego, California, so that she could attend law school.  RW lived           
          with petitioner in Indiana before petitioner moved to San Diego.            
          Petitioner’s move to San Diego occurred in the middle of RW’s               
          eighth-grade school year.  RW did not move to San Diego with                
          petitioner.  Before fall 2000, petitioner assumed that RW would             






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